Perrenoud v. Perrenoud’s Empirical Analysis
1971
Citation profile
50 state decisions
How this case has been cited
Cited by 50 later decisions — most recently October 2012 · most notably Padron v. Lopez (2009), Beebe v. Chavez (1979)
50 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Pierce v. Board of County Commissioners · Chapsky v. Wood · White v. White · Lyerla v. Lyerla · Browning v. Lefevre
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 50 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““. . . The validity of a divorce decree cannot be questioned in a collateral proceeding concerning any rights arising out of a marital relation, by a spouse who takes advantage of such decree by remarrying. . . .” (p. 571)”
2 later decisions quote this exact passage · from the majority““Frequently courts have been faced with the problem whether to give ‘full faith and credit’ or ‘comity’ to a sister state’s decree and refuse to reexamine its merits, or to exercise their own discretion and protect the welfare of minor children within their jurisdiction. . . . This court has recognized that a decree of a court of one state having jurisdiction relating to the custody of minor children, is, under the doctrine of ‘comity’ prevailing among sister states, entitled to recognition in this state. However, full faith and credit has only limited application to child custody decrees; it is inherent in the nature of such a decree that it is not final and conclusive, but is subject to the right of the parties to show a change of circumstances and conditions. . . . “It is apparent that . . . the door is open wide, so to speak, to ‘forum shopping’. . . . Some decisions point out that such abuse may be prevented by the imposition of the ‘clean hands’ doctrine which prevents a parent from invoking the court’s jurisdiction if he is a fugitive from the state issuing such decree, or has made misrepresentations in some way to obtain the custody of the children, or is flaunting a foreign proceeding or decree. The doctrine seems to be making advancement in family law and is being relied upon in some jurisdictions where the circumstances merit its application. In cases of this character, the court is dealing with a matter equitable in nature where the child’s welfare is the paramoun”
1 later decision quote this exact passage · from the majoritye.g. Jolly v. Avery“"7. The paramount concern of courts in every child custody proceeding is the welfare of the child. “8. In the interest of a minor child’s welfare, a court of this state, when the child is physically present therein, has jurisdiction over his care, custody and control, although the court of a sister state has ‘concurrent jurisdiction.’ “11. Full faith and credit has only limited application to a child custody decree; it is inherent in the nature of such a decree that it is not final and conclusive, but is subject to the right of the parties to show a change of circumstances and conditions.””
1 later decision quote this exact passage · from the majoritye.g. Miracle v. Miracle
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.